Compliance & MAR Disclosure

1. Service classification

1.1. Botely distributes general investment research and investment recommendations within the meaning of Article 3(1)(35) and Article 20 of Regulation (EU) 596/2014 (MAR), as supplemented by Commission Delegated Regulation (EU) 2016/958.

1.2. Botely is not providing investment advice within the meaning of Article 4(1)(4) of Directive 2014/65/EU (MiFID II), nor portfolio management within the meaning of Article 4(1)(8) MiFID II. Recommendations are broadcast cross-tenant, identical for all subscribers of a given tier, and not based on individual circumstances.

1.3. The underlying perpetual contracts are derivatives within the scope of MiFID II as clarified by the ESMA Public Statement of 24 February 2026 (ref. ESMA35-243228190-8024). They are excluded from the scope of Regulation (EU) 2023/1114 (MiCA) by Article 2(4)(a) MiCA, and the Service is therefore not a CASP service.

2. Producer identification (MAR Article 20(1)(a))

2.1. Producer of the recommendations: Botely — Italian limited liability company to be incorporated prior to commercial launch. Until then, the service is operated in pre-launch by the founding team in their personal capacity.

2.2. Contact for compliance matters: compliance@botely.trade.

2.3. Competent authority: not applicable. Botely is not a MiFID II investment firm and does not provide investment services requiring authorisation; the Service falls outside the perimeter of authorisations required by Directive 2014/65/EU, on the basis of the conditions described in this document and in the Terms of Service. This conclusion has been reached on the basis of an internal legal analysis and will be confirmed by an external legal opinion signed by qualified counsel prior to commercial launch.

3. Methodology disclosure (MAR Article 20(1)(c))

3.1. The methodology used to generate recommendations is described on the public `/methodology` page. The disclosure covers, at a minimum: (a) the categories of technical indicators used, (b) time frames and markets covered, (c) frequency of signal generation, (d) the conceptual logic of take-profit, stop-loss and maximum-hold rules, (e) the registry of strategy versions with a changelog between versions.

3.2. Approach: rule-based algorithmic strategies (momentum / trend-following / volatility-breakout) applied to hourly and 4-hourly candle data and to a regime indicator (ADX/DI) computed on ETH-USD.

3.3. Markets covered at the Effective Date: BTC-USD, ETH-USD, SOL-USD and BNB-USD perpetual contracts on Hyperliquid.

3.4. Strategy versioning: every configuration change produces a new version (e.g. v6.4, v7). The version applied at the moment of signal generation is included in each recommendation as a cryptographic hash (`methodologyHash`) for independent verifiability. The full strategy specification per version is published on `/methodology`.

3.5. Performance disclosure: aggregate, anonymised historical performance (backtest and live) is published on the public `/performance` and `/backtest` pages, accompanied by the mandatory caveat that past performance is not indicative of future results, and the assumptions underlying each calculation (starting capital, fees applied, slippage assumptions, leverage).

4. Conflicts of interest (MAR Article 20(1)(d))

4.1. Team trading: members of the Botely founding team operate the same strategies on personal accounts at the venue (legacy bot accounts currently live on Hyperliquid). This is fully disclosed to subscribers: any potential overlap between team positions and signals received by subscribers is structural and known.

4.2. No payment for order flow: Botely receives no payment, rebate or other remuneration from any venue (including Hyperliquid) in connection with subscriber activity.

4.3. No revenue-sharing with third parties: Botely receives no commission or referral fee from any of the execution venues listed on the `/exchanges` page. Subscribers are free to choose any venue at which to execute (or not execute) the signals.

4.4. No proprietary positions taken on the back of subscriber signals: the founder's positions are opened on the basis of the same algorithmic signals distributed to subscribers, not in anticipation of those signals.

5. Distribution and record-keeping

5.1. Broadcast cross-tenant: each recommendation is distributed to all subscribers of the relevant tier simultaneously and with identical content. Differentiation between tiers concerns the delivery channels (webhook, Telegram, email, in-app feed) or delay only, never the substantive content of the recommendation.

5.2. Recommendations register: Botely maintains a register of recommendations issued, including timestamp, full content, version of strategy in force, distribution list (anonymised or with technical identifiers). The register is retained for at least five years from the date of generation.

5.3. Channels: webhook (HMAC SHA-256 signed payload), Telegram, transactional email, and an in-app feed in the subscriber's reserved area.

6. Geo-restrictions

6.1. The Service is not available to residents of the United States, the United Kingdom, Canada, Israel, Iran, North Korea, Russia, Belarus, and any other jurisdiction subject to comprehensive EU restrictive measures or included in the FATF list of high-risk jurisdictions. See the Terms of Service, section 6, for the complete list.

6.2. Geo-blocking is enforced through (a) GeoIP at signup and on subsequent access, (b) declaration of residence in the signup form, (c) KYC verification of residency. Geo-blocking for financial services is lawful under Article 1(3) of Regulation (EU) 2018/302 (Geo-blocking Regulation), which excludes financial services from the scope of the prohibition.

7. AML and Customer Due Diligence

7.1. Botely is not directly a designated AML-obligated entity under Directives (EU) 2018/843 (5AMLD) and (EU) 2018/1673 (6AMLD), nor under Italian Legislative Decree 231/2007, in the Service's current configuration (no investment service, no exchange of crypto-assets, no custody).

7.2. Notwithstanding the above, Customer Due Diligence (CDD) is applied at signup as a precaution, in line with our payment processor's compliance requirements and as a fraud-prevention measure. CDD is performed by a specialised KYC provider (Sumsub or Onfido) and includes: identity verification with a government-issued document, liveness check, residence verification, screening against international sanctions lists and politically-exposed-person lists.

7.3. Retention: KYC data are retained for 5 years from the end of the relationship, in line with Article 31 of Italian Legislative Decree 231/2007.

8. Custody and funds segregation

8.1. Botely is non-custodial. We do not hold, at any time, in any form (including encrypted at rest), the wallet keys, mnemonics or any other means of access to subscriber funds.

8.2. Subscribers self-custody on the venue (Hyperliquid) using their own wallet. Botely's role is limited to producing and distributing the signal.

8.3. The optional execution path ("Model B" — execution by Botely using permissioned API trading keys delegated by the subscriber) is not implemented at the Effective Date and will not be implemented without prior MiFID II authorisation, an authorised partnership, or restriction of the service to professional clients within the meaning of Annex II of Directive 2014/65/UE.

9. Insurance

9.1. Professional indemnity insurance and cyber liability insurance will be in place prior to the commercial launch of the Service, with policy limits commensurate with the volume of activity and the nature of the risks.

10. Governance

10.1. Compliance officer / MLRO: designated at the latest by the incorporation of the operating entity.

10.2. Data Protection Officer: appointed at the latest by the incorporation of the operating entity; contactable at dpo@botely.trade in the interim.

10.3. Independent legal opinion: the legal classification of the Service summarised above and in the Terms is supported by an internal legal analysis. A signed opinion from external qualified counsel specialising in EU fintech and crypto-derivatives will be obtained prior to the commercial launch. A summary will be published on this page once available.

11. Reporting concerns

11.1. To raise a compliance concern, suspected misconduct or a regulatory question regarding the Service, please write to compliance@botely.trade. Confidentiality will be preserved to the extent possible under applicable law.

11.2. For market-abuse-related concerns (insider information, market manipulation), please use the same channel; we will escalate to the relevant competent authority where appropriate.

Contact

• Botely — Italian limited liability company to be incorporated prior to commercial launch. Until then, the service is operated in pre-launch by the founding team in their personal capacity, contactable at the addresses below.
• compliance@botely.trade
• privacy@botely.trade (privacy / GDPR)
• dpo@botely.trade (DPO)
• Address (post-incorporation): To be confirmed at incorporation.

These documents are published in English (canonical) and Italian. In case of conflict between the two versions, the English version prevails for interpretation.

Changelog

• v1.0 — 2026-05-14 — Initial publication.